IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA 
FERDINAND J. MACK, JR 
an infant 
Plaintiff ' 
Civil Action No. 77-0916 
v 
JOSEPH A. CALIFANO, JR. et al 
Defendants 
FILED 
FE0-6i97g 
JAMES F, DAViY, Clerk 
THMNAND J. MACK 
ATTOIINKT AT LAV 
mum im 
OLD TOWN CBNTKR 
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WUTKVIUJ: MARYLAND 
V— 80 
SUPPLEMENTAL AFFIDAVIT OF RUTH HUBBARD IN SUPPORT 
OF MOTION FOR PRELIMINARY INJUNCTION 
I Ruth Hubbard being first duly sworn state as follows: 
I have read and am familiar with the document entitled IMUA-18, 
and the statement of understanding and agreement dated May 23, 1977. 
The opinions expressed by me in my previous affidavit filed in this case 
are unchanged. At the time those opinions were expressed, I was 
familiar with the E . coli which this document indicates will be utilized 
for the Ft. Detrick experiments. 
As set forth in the attached memorandum of Drs . Goldstein, Orego 
and Youderian to Donald s. Frederickson, Director, National Institutes 
' of Health, dated May 30, 1976, the viability of enfeebled strains of 
E. coli in the presence of.DNA remains, and will remain, unknown until 
A 
the DNA is inserted into the organism. Preliminary published experiment# 
already show that viability can be altered when foreign DNA is inserted 
into E. coli. 
»oi tr»*sso 
[Appendix C — 187] 
